Nathanael Greene's Blog: Solving Global Warming

A coal powered ethanol plant and a test of the new RFS

2008-05-14T18:55:01Z

In a little town in central Pennsylvania, a company called Sunnyside Ethanol, LLC (owned by Consus Ethanol, LLC) wants to build an 80 million gallon per year corn ethanol refinery that would get its heat and power from a waste coal boiler. The project would stand about 150 yards from the town's high school and a stone's throw from half a dozen houses. Waste coal, in case you don't know, is the stuff that's not good enough to burn in a regular coal plant. Needless to say, it's pretty nasty stuff.

This local news TV clip gives some good basics and introduces Pamela Sheeder, a local mother and leader of Citizens for a Clean Curwensville. (If you watch the video, take note that while the project has an air permit, it hasn't started construction. Also, what do you want to bet the borough council president doesn't have children at the high school.) These two articles introduce the only local councilman, Samuel Ettaro who has stood up against the project to ask the important questions.

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Now those of you who have been reading my blog or the popular press may think, what a sec, are the lifecycle GHG standards in the new RFS supposed to stop this sort of a project? Others who read this recent Inside EPA article (subscription, but here's the first paragraph in case: [1]) about how most of the growth in the corn ethanol industry is grandfathered and thus exempt from these standards may think, so this is one of the projects that squeaked through. No disrespect, but both groups are wrong.

The RFS establishes criteria for fuel that can be used by the oil companies to comply with the standard. The law requires that all renewable corn-based ethanol used to comply with the RFS “produced from new facilities that commence construction after the date of enactment of this sentence, achieves at least a 20 percent reduction in lifecycle greenhouse gas emissions compared to baseline lifecycle greenhouse gas emissions.” In other words, if someone want to make substandard fuel, they're allowed, but you got to wonder who is going to buy it.

As to the grandfathering provision embedded in the language above, it exempts fuel produced at existing facilities and facilities that commenced construction on or before December 19th, 2007, from the 20% greenhouse gas reduction requirement. The US Environmental Protection Agency is responsible for implementing the RFS and has not promulgated a definition for “commenced construction” in this context. The definitions that EPA has used elsewhere when implementing air pollution regulations generally require a project to have all of its permits, and to either have made large, irrevocable, construction-related financial commitments or to have begun actual on-site construction.

The project in question doesn't have local land-use or building permits, reportedly doesn't have title to the land, may not even have all of its financing lined up, and certainly hasn't broken ground. In other words, there's no way under any existing regulatory definition of "commence construction" that this project is anything other than a new project. Therefore, its ethanol is going to have to meet the 20% reduction requirement gasoline to be considered “renewable fuel.”

Now a legal eagle among my loyal readers will point out that EPA is allowed to lower the 20% requirement to 10%. But this facility is using waste coal to convert corn into ethanol. Even under traditional lifecycle analyses this combination can't come close to a 10% reduction and the definition of lifecycle GHG emissions in the RFS goes beyond the traditional approaches in very important ways. While EPA is in the process of developing the regulation to implement the lifecycle definition, nevertheless, I find it extremely unlikely that ethanol from a facility that uses waste coal for process energy would be able to meet this lifecycle emissions requirement for the following two reasons:

· Traditional lifecycle analyses have estimated that ethanol refined at a facility using coal for process energy produces more greenhouse gas emissions than gasoline over both fuels’ lifecycles. NRDC’s internal calculations historically have suggested that using combined heat and power can improve this balance, but only to the point of making the ethanol just slightly better than gasoline. The figure below comes from a peer reviewed journal article authored by one of the foremost authorities on the lifecycle greenhouse gas emissions of ethanol, Michael Wang from Argonne National Laboratory. As this figure suggests, according to traditional lifecycle assessments, unless a coal-fire ethanol refinery is not drying its distiller grains, the ethanol produced would not comply with the minimum standards in the RFS.

-Studies published in Science earlier this year have shown that emissions from land-use changes caused direct and indirectly by the growing of crops in order to make biofuels can dominate the lifecycle emissions and have been either ignored or significantly under estimated in traditional lifecycle analyses. While the assessment of emissions from land-use changes caused indirectly by biofuels is at very early stages, the definition of lifecycle GHG emissions in the Energy Independence and Security Act explicitly requires EPA to include these emissions. Even if the values suggested in the Science articles prove to be off significantly, including emissions from land-use change will make it all but impossible for ethanol produced at a facility that uses coal for process energy to meet the standards in the RFS.

So if the project is not going to be exempted and will have to meet the GHG standards but by virtue of using waste coal doesn't have a chance in hell of complying with those standards, why is it being built? And just as interestingly, who is financing it and where's the due diligence? Or is there a market for substandard, uncertified ethanol? And if there is what does that say about the need for ethanol incentives?

If you have any answer, I'm all ears. This is one project that no one should be interested in building or paying for. We have to wake up the financial community towns like Curwensville don't get stuck with half baked, fully polluting dinosaurs like Sunnyside Ethanol.

[1] From Inside EPA article:

Despite draft modeling showing that coal-fired ethanol plants will exceed the energy law's lifecycle greenhouse gas (GHG) standard, agency officials say that few existing facilities will be subject to the GHG standard because facilities exempted from the standard by Congress will likely be able to provide almost all the fuel needed to meet the law's 15-billion gallon corn ethanol mandate.

Op-ed on biofuels, food prices, and GHG emissions

2008-05-14T01:55:11Z

It has already been such a crazy week that I'm only just getting a chance to do my own PR. On Monday, the Minneapolis Star Tribune ran an op-ed coauthored by my friend Lee Lynd and yours truly. Lee is one of the foremost thinkers on consolidated bioprocessing of lignocellulosic biomass into fuels, a professor at Dartmouth, and the chief technical officer at Mascoma. So he knows what he's talking about, and it's always a pleasure to piggyback on the clear thinking of smart people.

I've written about the gist of the article here before, but to reiterate what I think are the three most critical points:

The solution to the food vs. fuel debate and the concerns about the GHG emissions of biofuels are one and the same--use the nonfood part of the plants and get the biomass off the land in doesn't interfere with food production or convert our wild landscapes rich in carbon (and biodiversity) into crops.
There is ample reason to believe that there is a significant amount of biomass that meets this criteria and that much more can be produced if the regulations guide the market to develop this material.
We need to build on the safeguards and standards adopted as part of the RFS in December with a low-carbon fuel standard and technology-neutral and performance based incentives.

The editor did a pretty good job cutting our 885 word original down to a svelte 663 words. For posterity's sake, I've pasted the full, original text below. There are two important substantive cuts both having to do with the importance of the context of biofuels.

The first came in the first paragraph where the second sentence originally read:

While these concerns should motivate greater efforts to do biofuels right, we must not throw the biofuels baby out with the bathwater – especially given the dearth of viable alternatives to power a sustainable and secure transportation sector.

But the part about the dearth of viable alternatives was dropped. I wrote about the reasons that we bother to struggle with biofuels a few weeks ago.

The second big cut came towards the end when this entire paragraph was dropped:

We need efficient vehicles, mass transit, and plug-in vehicles, but along with reducing demand for liquid fuels, we need to find new ways to sustainably produce them. A major focus of the renewable fuel standard is expanded production of cellulosic biofuels. Farmers and producers involved in the existing biofuel industry are generally open to such an expansion as long as they are not left holding the bag.

So now, for your reading pleasure, I offer the unedited original text of our op-ed:

Rethink Biofuels But Watch the Bath Water

Nathanael Greene and Lee Lynd

Biofuels were riding a wave of popularity only a few months ago, but now suddenly they’re being roundly condemned in light of rising food prices and recent studies showing that biofuel production can exacerbate climate change. While these concerns should motivate greater efforts to do biofuels right, we must not throw the biofuels baby out with the bathwater – especially given the dearth of viable alternatives to power a sustainable and secure transportation sector. Rather than retreating from current policies, which do more for smart biofuels than many realize, Minnesota and the nation should follow California and Massachusetts in building – wisely – on this foundation.

The current rise in food prices is causing a humanitarian crisis that we must address. But if we want to fix the problem, we first need to understand what’s behind it. Biofuels are a modest part of the food price picture, consuming only 4 percent of world grain, and there is little evidence that food prices would be much lower if we did not produce biofuels. The primary reasons for skyrocketing food prices include our rising energy costs, increased demand for meat in developing countries, drought, and misguided national and international agricultural policies.

Global warming is also a crisis, and two recent papers in Science identify issues that we must pay attention to if biofuels are going to contribute to lowering global warming pollution. The papers point out that if the demand for biofuels causes unmanaged forests or grasslands to be converted to row crops, we must account for the global warming pollution released during that conversion, and that these emissions can overwhelm the benefits of displaced gasoline or diesel consumption. However, showing that these undesirable results could happen given unsustainable practices in no way establishes that they must happen. There are solutions.

We can produce biofuels in ways responsive to these challenges. This can be done by making biofuels from non-food biomass (woody material, grasses, stalks and stems), while also producing this “cellulosic” biomass in ways that neither compete with food production nor cause increased global warming pollution that comes from converting wild landscapes to row crops. In other words, using the right part of plants and producing them in the right ways take biofuels out of the food price equation and makes them part of the solution to global warming.

Such cellulosic biomass is available from a greater diversity of sources than row crops, including wastes, land that cannot grow food crops or is not needed for food production, and potentially new approaches that coproduce food and biofuel feedstocks. Several studies have shown that wastes from the forest products industry, crop residues and winter cover crops could provide hundreds of millions of tons of biomass annually and certainly enough to comply with the recently adopted 21 billion gallon federal renewable fuel standard for “advanced biofuels.” Higher production levels are likely possible, particularly in light of emergent market forces and public policies.

The renewable fuel standard, signed into law in December as part of the Energy Independence and Security Act (EISA), is the first biofuels policy to mandate a shift in our production practices in a way that directly addresses global warming pollution and indirectly – by promoting sustainable cellulosic biofuels - will address the food production challenge. The Act establishes minimum global warming pollution standards for biofuels and critical land-use safeguards. New biofuels projects that increase global warming emissions—including emissions from land conversion—are not permitted under EISA. Most of the mandated 15 billion gallons of corn ethanol production capacity required by the Act is already in place or under construction. As expansion beyond this level is unlikely to be favored by either market forces or regulation, the ceiling of corn ethanol production appears to be in sight.

The low-carbon fuel standard, first embraced by California and recently by Massachusetts, goes beyond setting a minimum standard and rewards the best solutions. This approach requires that oil companies reduce the average global warming pollution of their fuels, but lets the market decide the best mix of options. Biofuels that provide the most reductions will certainly play a big role, but so can other technologies such as plug-in vehicles that use electricity and natural gas powered cars and trucks.

We need efficient vehicles, mass transit, and plug-in vehicles, but along with reducing demand for liquid fuels, we need to find new ways to sustainably produce them. A major focus of the renewable fuel standard is expanded production of cellulosic biofuels. Farmers and producers involved in the existing biofuel industry are generally open to such an expansion as long as they are not left holding the bag.

In the middle of April, six committees of Minnesota’s House and Senate jointly gave the low-carbon fuel standard a full initial hearing. We should build on foundation provided by the renewable fuel standard and follow the state level leadership with a federal low-carbon fuel standard as part of comprehensive climate legislation. We also need to realize that better biofuels policies are no excuse for not addressing world hunger head on through better agriculture and food aid policies. More generally, we should go beyond all or nothing headlines and pursue a transition to biofuel strategies that realize the compatible objectives of replacing oil, expanding opportunities for existing producers, and securing both food supplies and a sustainable future.

Nathanael Greene is a senior policy analyst for the Natural Resources Defense Council; Lee Lynd is a Professor of Engineering at Dartmouth and Chief Scientific Officer of Mascoma Corporation.

In hand wringing over biofuels mandate, safeguards at risk

2008-05-08T01:47:20Z

The Hill was alive with the sound of finger pointing and hand-wringing yesterday when I testified before the House Committee on Energy and Commerce, Subcommittee on Energy and Air Quality about the RFS. (All the testimony including mine is available on the Subcommittee's web site. Mine is also available here, on NRDC's site, and my oral statement, which I basically read, is here if you want the 600 word version.) The hearing was ostensibly an EPA oversight hearing to learn about implementation of the RFS, but it was really mostly a platform for two groups of legislators: 1) those that want to reduce or eliminate the RFS and replace it with more domestic oil, liquid coal or both and 2) those that want to gut the safeguards in the RFS.

Any number of oil and coal patch republicans or dems would probably vie for the leadership of the first group, but the ranking member of Energy and Commerce, Joe Barton (R-Texas) would get my vote. He has a bill to repeal the recent RFS and reinstate the 2005 RFS. This would cut the corn ethanol mandate in half and entirely eliminate the advanced biofuels requirements and all of the minimum lifecycle GHG standards and land and wildlife safeguards.

The leader of the second group is Rep. Stephanie Herseth Sandlin (D-S.D.) who has a bill (H.R. 5236) to replace the current definition of eligible woody biomass, which includes the safeguards, with the version that passed in the Senate last year, which effectively allows in all wood.

Now the politics here are really strange because of course the anti-biofuels fossil fuel group was more than happy to support the anti-safeguard crowd, but many of the anti-safeguard are strongly pro-corn. So when Rep. Herseth Sandlin testified about her bill she had to spend half her time talking about how great corn ethanol is and Rep. John Shimkus (R-Ill) basically yelled at his colleagues. "This is very frustrating, how short-sighted we are to walk away [from corn ethanol]," he boomed, and then at the end, he added that what we really needed to do was pass the Herseth Sandlin bill and add liquid coal to the mix.

Adding to the array of strange bedfellows, four environmental groups sent a letter to the Subcommittee's chair adding their voice to that of the Governor of Texas, and a bunch of Senate Republicans calling for a waiver of the current RFS.

A voice of reason came in a statement from the Chair of Energy and Commerce, Rep. John Dingell (D-Mich.). As the first line of a comprehensive article in the E&E Daily (subscrip) by Alex Kaplum put it: "House Energy and Commerce Chairman John Dingell (D-Mich.) threw cold water yesterday on the growing cry to scale back the federal ethanol mandate Congress approved last year."

Among other things in his statement, he says the following:

I would observe that the ink had hardly dried on this new law when the clamoring began to alter the RFS, and these requests for Congressional intervention continue. In my view, amendments to the law at this time would be unwise and could lead to unintended consequences.
I believe that all stakeholders would be well-advised to consult with the EPA as it develops the rule and try to address any concerns within that forum. If unresolved issues still remain after the rule is finalized, there may be need for Congressional action. To act in advance of that date, however, undermines important processes.

Another good article in E&E Daily on Monday by Ben Geman got my perspective on these various efforts right:

Nathanael Greene, a biofuels expert with the Natural Resources Defense Council, said biofuels are among the many factors that are contributing to increased food costs. But he does not see altering the biofuels mandate as the answer.
Instead, he argues that lawmakers should "build on top" of the mandate by altering biofuels tax credit and tariff policy. Lawmakers should encourage biofuels that fare best in terms of greenhouse gas reductions and other environmental factors, he said, which would thereby steer production toward cleaner fuels that do not compete with food.
"The solution to a lot of the global warming concerns, particularly the land-use emissions concerns, and the solution to getting biofuels out of the food price equation are the same thing," he said.
Greene is also concerned that reopening the mandate would allow for "mischief," such as a push to weaken environmental restrictions in last year's energy bill.

The Herseth Sandlin bill certainly qualifies as mischief in my book. While my testimony provides a full explanation of why we think the RFS got the definition of renewable biomass and woody biomass specifically right, I'll summarize our points here:

First it's important to understand that our wild landscapes and federal lands are only becoming more critical to wildlife and for their ecosystem services and as stores of carbon as global warming puts increased pressure on our lands. So the need for safeguards is greater than every. Still the new RFS allows the vast majority of woody feedstock that is likely to ever be economically viable for biofuels. It only excludes: old growth, few remaining grasslands, our most sensitive landscapes, federal lands, and the conversion of natural forests to forest plantations.

In other words, all the material from a forest plantation can be used, as can the material from a naturally managed forest (one that uses natural regeneration). But you can't convert a natural forest to a forest plantation. Plantations may look like forests but they're deserts from the perspective of biodiversity.

The federal land exclusion is a big sticking point for Herseth Sandlin, who has a number of interests that want to harvest the Black Hills for energy. But "preventative thinning" from a forest is ostensibly to restore the forest health and reduce the risk of fires. This means that you don't want the material to grow back, which makes it an open loop source of carbon not unlike the carbon from coal. Furthermore, the evidence that thinning helps reduce the risk of fire is uncertain at best and there are studies that suggest that it actually makes fires worse. And finally, for that material that is already being cut and left in the forests, there are better more local and more appropriately scaled options such as producing heat and power for local communities.

The only thing that I would add to Ben's E&E Daily article is that I actually offered three steps that Congress should take to build on the RFS:

Adopt a low-carbon fuel standard, as California and Massachusetts are planning to do.
Pass comprehensive climate legislation built around a mandatory, economy-wide carbon cap and a carbon credit trading system.
Reform the various existing biofuels tax credits and import tariffs to be a single technology-neutral, performance-based credit to encourage water efficiency, reduced water pollution, better soil management, and enhanced wildlife management.

Massachusetts moves to adopt low-carbon fuel standard

2008-04-25T03:26:10Z

Yesterday, in a major step forward for biofuels policy, the Massachusetts governor, senate president, and speaker of the house jointly called for the adoption of a low-carbon fuel standard. The LCFS is a technology-neutral, performance based approach to reducing the greenhouse gas emissions from transportation energy. This a vast improvement over the technology specific, volume incentives and mandates that until recently dominated US biofuels policies.

The way a LCFS works is that the full lifecycle GHG emissions from the fuels each oil company is selling are added up and divided by all the energy in that fuel. This becomes the company's average fuel carbon intensity. Overtime under the LCFS, the oil companies have to reduce this average carbon intensity by mixing in sources of transportation energy with lower lifecycle GHG emissions. In California, which was the first to move towards a LCFS and is now in the process of developing the regulations, the goal of the LCFS is to require a 10% reduction in carbon intensity by 2020. In other words, a company could replace all of their current fuel with an alternative that has 10% lower lifecycle GHG emissions, or half with an 20% lower alternative, and so on. The LCFS rewards the sources of energy that have the lowest lifecycle GHG emissions. Just as importantly, it penalizes high carbon fuels such as liquid coal. (Check out this awesome short video if you don't know how bad liquid coal is.)

As I've written about before, this is stark contrast to the original RFS, which was a simply volume mandate that totally ignored how the biofuels were produced. Our current tax credits for ethanol and biodiesel and our import tariff on ethanol are similarly blunt, ignoring the impacts or benefits of the fuels' lifecycle. As I've written about before, the current RFS was the first step towards setting performance based requirements. It sets minimum lifecycle GHG emissions requirements for fuels from new facilities and establishes land-use safeguards.

But the new RFS is still a volume mandate for a specific set of fuels and these standards are floors--you have to be a biofuel and you have to be above the floor to qualify. If you're electricity or natural gas you can't compete and you don't get anything for being better than the floor.

While they are moving ahead in the state, they also invited the other states that are part of the Regional Green House Gas Initiative to join Massachusetts. This is exactly the type of leadership we need, and it should be mutually reinforcing with efforts already underway in the Northeast.

NESCAUM has been doing a study of a LCFS for the air regulators of the NE states, but this is should throw that effort into high gear and greatly increase the chances that the other governors will follow Massachusetts' lead.

The announcement builds on the findings of the Massachusetts' Advanced Biofuels Task Force, which were released yesterday. I testified before the Task Force, and my primary recommendation was that they adopt an LCFS, so that's extremely gratifying. Importantly they repeatedly in the press release and theTask Force report refer to the importance of addressing GHG emissions from direct and indirect land-use change.

Interestingly, the ABTF stuck to its recommendation that the state adopt a biodiesel and bioheat mandate, which I recommended against, but they appear to have amended these mandates to link them to the lifecycle GHG accounting that is central to a LCFS and made the mandates "as technology neutral as possible." I have yet to read the details, but this sounds workable to me and may be a good model for other places that eager to do a bioheat bill.

Here's a summary of the ABFT recommendations from the Executive Summary (PDF, 2MB):

• Prioritize efforts to achieve near-term implementation of a regional, technology-neutral and performance-based Low Carbon Fuel Standard (LCFS), with Massachusetts leading the way.
• While a Massachusetts LCFS is being developed, pass amended versions of the legislation you cosponsored, implementing targeted transitional biofuels mandates and exempting cellulosic biofuels from the state gasoline tax, with a sunset date. Both the transitional mandates and cellulosic fuel exemption should require significant greenhouse gas reductions and other environmental protections, including direct and indirect impacts such as those on land use. The mandates and cellulosic tax exemption should be as technology-neutral as possible, and should phase out as a Low Carbon Fuel Standard comes into existence.
• Support pilot deployment in the state fleet of plug-in hybrid and all-electric vehicle technology in light- and heavy-duty vehicles, as well as fuel-efficient flex-fuel vehicles.
• Develop infrastructure necessary for consumer use of biofuels and implement limited-cost investments in equipment for ethanol and biodiesel distribution, such as E85 stations along major state highway corridors, subject to budget constraints.
• Develop standards for full lifecycle evaluation of biofuels that consider their carbon and other environmental impacts, including direct and indirect land use impacts.
• Parallel to progress on biofuels, continue to explore policy options for vehicle efficiency and reducing vehicle miles traveled.

Cape Wind is needed now; MMS should move quickly

2008-04-21T20:43:43Z

Today we pressed send on our written comments on the Draft Environmental Impact Statement (DEIS) for the proposed Cape Wind offshore wind project.The DEIS was prepared by the Mineral Management Service as part of the permitting process for the project. Based on our review of this the information in the U.S. Army Corps of Engineers DEIS and other analyses that have been done on the project, NRDC has concluded that the project’s environmental benefits will far outweigh its impacts.

While NRDC has long been a strong supporter of increased use of wind energy, we have moved cautiously when it came to the Cape Wind project. This has been out of respect for the environmental review process—a corner stone of modern environmental policy—and wanting to make sure that the first offshore wind project in the US gets it right. The results of the DEIS and the other studies we have reviewed make it clear to us that the Cape Wind project will be a big win for the environment and is urgently needed. However, no energy project is without its potential environmental impacts and, to address these, NRDC strongly recommends that the Final Environmental Impact Statement (“FEIS”) and any lease, easement, and right-of-way for the Project include specific monitoring and mitigation conditions to protect the coastal and marine environments.

The technology for producing electricity from wind energy has improved greatly over the past twenty years, and wind—on and offshore—now represents one of the most promising sources of emissions free electricity. Indeed, offshore wind power is probably the New England’s largest untapped renewable energy resource and a vital resource for the entire country.

The potential benefits of the project are undeniable. The project would produce a maximum electric output of 468 MW and an average daily output of 182.6 MW free of air and water pollution. In addition to the local and regional air pollutants, such as NOx and SOx that the project would avoid, the project would reduce emissions of carbon dioxide—the pollutant most responsible for global warming by 0.88 million tons per year. As UCS calculated as part of their comments, this means that Cape Wind will reduce expected growth in CO2 emissions from the power sector in 2014 by about 9%.

This would be an important contribution to fighting global warming for two reasons: 1) it would do more than any other renewable energy source of electricity in New England to avoid global warming pollution and 2) it is by far the largest single contribution that Cape and Islands—a region that is exceptionally vulnerable to global warming—can make to reducing greenhouse gas emissions.

To address the environmental impacts of the project, NRDC recommends that the FEIS and lease, right-of way or easement for the project include the following: 1) a requirement for a comprehensive underwater acoustic monitoring system that not only measures the levels of underwater noise but that detects the approach of marine species into the safety zone around the turbines, 2) a requirement that construction activity be scheduled so as to avoid periods of peak abundance of threatened or endangered species, 3) a requirement that additional surveys be conducted to reduce remaining uncertainty regarding the threat of impacts to the federally endangered Roseate Tern, and 4) a requirement—detailed below—for a comprehensive Environmental Management, or adaptive management, system.

Given the relative lack of experience with offshore wind projects in this country, there is the possibility that the scale of certain impacts will only become clear overtime. It is important to the future not only of this project but to offshore wind generally, that there be an effective system be in place to monitor and adjust operations to avoid such impacts.

To that end, we call on MMS to include in the FEIS and as a condition of any lease, easement or right-of-way, a detailed and comprehensive Environmental Management System for monitoring and mitigating potential impacts associated with project construction and operation. MMS’s interim policies and Best Management Practices, issued as part of its Alternative Energy and Alternate Use (AEAU) Program, require MMS and lessees and grantees to adopt adaptive management that will include monitoring of activities to ensure that potential adverse impacts of OCS alternative energy development are avoided (if possible), minimized, or mitigated.

The Environmental Management System should achieve the following goals:

· be guided by a panel of government and academic scientists,
· include specific adaptive responses for environment impacts judged to be reasonable possibilities at the chosen site,
· include a framework that prevents abuse of the program and which also protects the economic interest of Cape Wind by establishing a reasonable budget for implementation costs and mitigation measures including possible short-term shutdowns,
· require monitoring during both construction and operation, and
· require that all data collected be made available to the public, in electronic form, in real-time when possible.

The urgency of stopping global warming increases regularly as the drumbeat of scientific studies about the quickening pace of climate change continues. Cape Wind will make an important contribution to the fight against global warming both through its immediate displacement of fossil fuels and by paving the way for greater use of offshore wind.

MMS should adopt our recommendations, finalize the EIS, and expeditiously permit the project with the recommended monitoring and mitigation measures.

The dangers of the food vs. fuel debate

2008-04-20T18:03:23Z

A quick review of a Google news search for "ethanol" and "food" is instructive. Here's an excerpt of the results:

Don't Blame Ethanol For Soaring Food Prices
A Worsening Food Crisis
Corn-Based Ethanol Tied to Higher Food Costs
Biofuels under attack as world food prices soar
Demand for Corn-Derived Fuel is Driving Up Food Prices, but New ...
It's time to scrap the ethanol
‘Biofuels suspension won’t help rice situation’
Food Riots Made in the USA (The Weekly Standard - Apr 18, 2008): "Right now, we're trying to run our cars on corn ethanol instead of gasoline. As a result, we suddenly find ourselves taking food out of the mouths of ..."
New 'Green' Body Count (FOXNews)

(Got to love that last one -- Fair and balanced as long as by "fair" you mean shill for the looney neocons and and "balanced" you mean gleefully biased.)

The food vs. fuel fight is in full swing. I've weighed in on it before and I'm working on an editorial with a friend to try to raise the profile of a few critical points:

There are many reasons food prices are high and the poor are starving including energy prices, increasing demand for meat as part of changing diets in developing countries, extreme weather events probably linked to global warming, misguided national and international agricultural policies, and certainly making biofuels from food crops too.
While corn ethanol consumes about 24% of US corn production and US corn production is about 40% of world corn production, ethanol consumes just 4% of world grain (corn, rice, wheat, soy, etc.). Common sense suggests that food-crop derived biofuels would a similarly small role in overall grain prices. While inelastic supply and demand curves can lead to disproportionate impacts, economic modeling confirms that biofuels are a modest part of the food price picture.
Nevertheless, just as we strive to develop biofuels with the largest greenhouse gas benefits, we should simultaneously strive to develop biofuels that don't interfere with food markets.
Fortunately, the solution to these twin challenges are the same--developing and deploying as quickly as possible biofuels made from the non-nutritive part of plant culled from our waste streams, grown on lands that have been degraded by poor management but have not reverted to their natural state, or integrated into food production in a way that neither diminishes food production or the quality of the land.
The RFS just adopted is not perfect, but it is the first biofuels policy to mandate a shift in our production practices in a way that will address these challenges. The minimum GHG standards, which require EPA to address both emissions from direct and indirect land-use, and the land-use safeguards (see our new factsheet on these) will over time make biofuels that do not compete for prime arable land or ecologically sensitive lands the only ones that can comply with the federal fuel mandate.
Now we need to take the next steps on our policies including adopting a federal low-carbon fuel standard and revamping our ethanol and biodiesel tax credits (and our ethanol import tariff too) to be performance-based and technology neutral.

While I worry that the current mud-fight over food vs. fuel will lead to dangerously blunt policies that would throw out the biofuels baby with the bath water, I worry more that the mud-fight will distract us from doing something serious about world hunger. The argument that we should address the starvation being caused by current high prices through minimizing the production of biofuels from food crops is wrong and distracts us from the real solutions. This argument is basically calling for addressing world hunger by encouraging overproduction here in the U.S. (Less corn ethanol means more supply, more supply means lower prices -- or so the argument goes.) But overproduction in developed countries comes at a high cost to our environment, to farmers around the world, and ultimately to the economies of the countries with the most hungry. Overproduction is what we’ve had for decades, and it has crushed farmers in developing countries around the world. Subsidized overproduction and the resulting cheap food does trickle down to feed more people, but it’s not sustainable -- nor is it the most effective way to feed the poor.

We can, and must, move biofuels as quickly as possible to non-food biomass grown and harvested in ways that does not aggravate the competition for land; we have to do this both to fight global warming and to disentangle biofuels from food prices. But scapegoating biofuels just distracts us from the policies that move the big levers. I'm not a hunger or poverty policy expert, but it seems obvious to me that in the short term dramatically increased food aid is key. And in the mid- to long-term keys would include ag development aid, better nutrition policy here at home to change our diet, and reducing oil consumption through vehicle efficiency, VMT reduction, electrification of transportation, and getting biofuels from non-food crops.

U.S. consumption of meat and oil are ultimately the biggest culprits here. The idea that changing our biofuels policy is the only thing the most affluent country on earth can do to make sure the poorest have enough food is just an abdication of responsibility.

Philpott and I discuss biofuels

2008-04-04T18:08:10Z

Two weeks ago, I wrote about some misguided claims by David Pimentel and what I saw as overly broad and overly pessimistic views on biofuels from cellulosic biomass by Tom Philpott. Last week, Tom paid my blog here a visit and posed some reasonable questions and invited folks to what will hopefully be an informative debate on his blog on Grist. So let's have at it.

Rather than start with our points of disagreement, I'd like to start with some points that I hope that Tom and many of our readers will agree with because in the end these points are the reasons that I and NRDC continue to struggle with biofuels despite all the challenges and controversies. First and foremost, we need to stop global warming by stabilizing atmospheric GHG concentrations at the equivalent of less than 450 ppm CO2. For us here in the US, this means reducing our GHG pollution by 80% below 1990 levels by 2050. Furthermore, we have to do this in a way that ensures that the cure is not worse than the disease. In other words, we have to try to stop global warming while also addressing our other major environmental and social challenges and we can't afford to exacerbate those challenges.

This is a daunting challenge and our current path is not going to get us there. We cannot extrapolate forward our current rates of consumption and our current rates of technological improvement and expect to get to a sustainable future. We need important technological innovations and changes to our policies. What's more, there is no single technological innovation that will magically put us on a path to sustainability. We need innovations and changes across our economy.

The good news is that even analysts as conservative and mainstream as McKinsey and Co. believe we can be on the right path by 2030 at little or no cost to our economy as long as we start now. However, it takes aggressive action and requires a wide array of technologies.

1 Constant 2007 dollars

2 Billions of tons of CO2 equivalent eliminated per year relative to business as usual projections

Source: NRDC analysis partially extrapolated from McKinsey report; see www.marketinnovation.org

And this is probably even more true in the transportation sector as it is in the rest of the economy. Our current path domestically and internationally is wildly unsustainable with demand growing and efficiency deteriorating (until our recent victory on increasing CAFE). As a result, gasoline demand is expected to roughly double in the US by 2050 under BAU.

Up to here, I'm hoping that we're all mostly in agreement.

Our options to bend the GHG emissions curve associated with transportation are fairly straight forward: improve the efficiency of our vehicles, change our mode of transport to more efficient ones, travel less, and put lower carbon fuels into our cars, trucks, planes and other forms of transport. When we look at trying to reduce the transportation sector's emissions by 80% from 1990 levels by 2050 through these options, it's not easy to make the numbers add up. In the light-duty vehicle sector, one of the most aggressive scenarios that we have analyzed relies on improving our vehicle fuel economy three fold, cutting our VMT 20% and ramping up the use of electricity to where it drives 50% of all VMT. (For modeling purposes, we assume all vehicles are flex-fuel plug-ins hybrids that use electricity for 50% of their driving and E85 for the rest. To be clear, we don't care if it's this configuration of vehicles and we certainly don't care what fuel molecule ends up being used.) Even under this scenario we still see the need for about 60 billion gallons (on an ethanol basis) of truly low-carbon biofuels (e.g. about an 80% reduction from gasoline lifecycle GHG emissions) to provide about 9 1.4 gigatonnes of CO2 equivalent GHG emission reductions. And even after that, the transportation sector is just barely carrying its weight in terms of providing emissions reductions.

(Note: 38 billion gallons on a gasoline equivalent basis equals 58 billion gallons on an ethanol basis because of the lower energy density of ethanol.)

What happens if these emissions reductions don't materialize from biofuels? Nothing, if we can get them from some other part of the transportation sector, but of course every other option faces technical and political challenges as well. Whether it is battery technologies, entrenched interests addicted to sprawl, or the challenges to rapidly scaling up renewable power and the associated transmission, no pathway is a technically and politically sure thing.

So what if these emission reductions don't materialize from the transportation sector at all? Again, nothing as long as we get it from some other sector, but again there are challenges everywhere we look. The bottom line is that we need lots of solutions and we need them all to provide as much pollution reduction as they can in a broadly sustainable way.

And that is why NRDC continues to struggle with biofuels. Not because I like ethanol or we like controversial and complicated issues, but because we're committed to stopping catastrophic climate change. To do that we can't afford to give up trying to figure out how to make potentially significant solutions work.

I'm going to leave off at this point and see if we're in agreement on the premise that we have to struggle hard to figure out how to make potentially significant solutions to the climate challenge work. There are perfectly valid questions about whether biofuels can technically and politically be made to be a solution (and I look forward to discussing them), but I want to make sure that we come to these questions with a shared sense of urgency around trying. We cannot afford blind optimism, but we must share a belief that we can and must over come enough of the technical and political challenges to the solutions to global warming to save our environment from ourselves.

Biogasoline and the search for renewable fuels that fit better

2008-03-26T22:10:10Z

Today Shell and a small biofuels start-up called Virent announced their collaboration on "biogasoline." According to the press release (here's the link to the free press kit):

Virent's BioFormingTM platform technology uses catalysts to convert plant sugars into hydrocarbon molecules like those produced at a petroleum refinery. Traditionally, sugars have been fermented into ethanol and distilled. These new ‘biogasoline’ molecules have higher energy content than ethanol (or butanol) and deliver better fuel efficiency. They can be blended seamlessly to make conventional gasoline or combined with gasoline containing ethanol. [emphasis added.]

I don't know anything about Virent's technology or what the "collaboration" with Shell really entails. (Apparently it has been going on for a year, so I'm not even clear what the news is that warrants a press release. For more on the business news angle, check out Cleantech.com. And here is some history from Cleantech blog and Biopact) But it's the last line of the quote above that I see as important.

While the technical challenges of dealing with ethanol's absorption of water and corrosiveness are eminently addressable, they do represent real costs. So it should surprise absolutely no one to see oil companies working hard to find renewable fuel molecules that fit into the existing system more easily. And, as I noted ages ago at the end of this post, this is great and should be warmly embraced by the biofuels industry and regulators alike.

We need to be wary of two things, though. First we need to test all new fuel molecules to make sure we address any unintended and currently unregulated emissions. Permeation of VOC from the fueling system and aldehyde emissions from ethanol are a perfect example of this. We need testing, and where necessary new regulations.

Second, we need to resist any calls to hold off on developing ethanol infrastructure while oil companies and startups work on these new molecules. The threat of having to invest in this infrastructure is one of main reasons that most oil companies will consider real investments in the biofuels sector.

The only other point of interest in the press release for me was the fact that Virent is using catalytic technologies to convert sugars to fuels--not gasification and not biotechnology. This goes to the point I made in this post about the explosion of different technology pathways currently being explored.

They haven't cracked the cellulosic conversion nut. They require water soluble carbohydrates; so someone else will have get the cellulose to that stage. In the end, who knows if this effort will pan out into something that is a better fit with our current infrastructure and has a better net energy balance as they claim? And what about water use and pollution and GHG emissions? But the more different pathways receiving real attention, the greater the chances are we'll find at least one that is a real improvement over the oil, ethanol, and biodiesel we have today.

Pimentel and Philpott pile on biofuels

2008-03-21T01:12:22Z

David Pimentel, writing earlier this week in the St. Louis Post-Dispatch, continues to make his case against corn ethanol and biofuels more generally. Dr. Pimentel has made a name for himself by repeating old data that is out of line with the peer-reviewed literature. (Check out Alex Farrell's EBAMM and the supporting materials from the related Science article to get a sense of where Pimentel's data an outlier.) The only news here is that Pimentel seems to have finally acknowledged that corn ethanol has a positive return of fossil fuel investment. From the article:

Cornell University's up-to-date analysis of the 14 energy inputs that go into corn production, plus the nine energy inputs invested in ethanol fermentation and distillation, confirms that more than 40 percent of the energy contained in one gallon of corn ethanol is expended to produce it.

That implies that the return on fossil fuel investment is about 2.5 (100%/40%).

Unfortunately he repeats his mistaken claim that much of the fossil fuel energy going into making ethanol comes from oil. It is almost exclusively natural gas, with some coal mostly in the form of electricity.

He also repeats his claim that ethanol from cellulose has a negative return on fossil fuel investment.This claim appears to be based on the misguided assumption that facilities processing cellulose would use fossil fuel energy to drive the process rather than use the lignin in the raw biomass. Not using the lignin would result in a major waste management problem, which is why all analysts who've tried to figure out how this technology might actually work assume the lignin would be put to productive use.

Check out NRDC's own, slightly dated analysis of the energy return on fossil fuel investment.

Speaking of cellulosic biofuels, Tom Philpott, writing for Grist, seems set on believing that this technology will never materialize. I've written before about why I'm optimistic about the future of cellulosic biofuels. Philpott draw on three sources for his dour view. In this earlier post, which he refers to, he cites a USDA analyst and a study out of Iowa State (PDF).

You'll excuse me if I don't give much credence to the USDA when the private sector is leading the way. Despite Philpott's cynical effort to discredit the academic study before citing it, it actually has a lot of cool aspects, but is an economic modeling exercise that in my admittedly quick review concludes cellulosic material would too expensive to develop absent of the RFS. Of course, we do have the RFS, so I'm not sure what that proves in terms of the future of cellulosic biofuels. Furthermore the modeling only looks a switchgrass competing with major commodities for land. But we don't want switchgrass to out compete food crops because that leads to higher food prices and indirect land-use conversion. Much better would be integration of food and biomass production, but that's hard to model.

The other source Philpott sites is a independent consulting firm, from which he draws the following quote:

The paper noted that there are only two cellulosic ethanol pilot plants currently operating in the United States. Other demonstration plants won't begin producing until 2010 or 2011, making the short-term EISA requirement of having 100 million gallons of cellulosic ethanol by 2012 unattainable.

Yet a quick scan of the 6 DOE commercial-scale cellulosic biofuels grants and related press releases reveals the following projected production capacity schedule:

All 140 million gallons will almost certainly not materialize by 2012, but it's not impossible. And in any case, failure to meet the first requirement in the bill is hardly the deathknell for cellulosic biofuels.

Giving voice to my biofuels birthday wishes

2008-03-12T21:53:45Z

So today is my birthday, and I have been struck dumb by a case of laryngitis. It seems somehow appropriate for someone who spends so much of his time talking. Of course at home, where I'm the lone male, nobody much respects my authority anyway, so not that much has changed--only now instead of my girls pretending they can't hear me, they really can't. In any case, it's all enough to make one a little philosophical. I haven't had more than a few seconds to rub together for the last few weeks, so given my current predicament, blogging seems like a good way to... express myself today.

I spent Monday at the Ecological Society of America's Conference on the Ecological Dimensions of Biofuels. It was an interesting, but ultimately frustrating day. While the stated objective of the conference was to help policy makers by bringing the best science to the table, there was a real dearth of synthesis and application of all the great "applied science" that was presented.

The presentation largely fell into two groups--studies of how to do biofuels wrong and studies of how to do biofuels right. What was missing was studies of how to get farmers and biofuel refiners to actually do what is right and not do is wrong. Thanks to the hard work of Amelia Nuding, NRDC presented this poster [large file designed to print out on 4'x6' format!] focusing on the ESIA07, but beyond that and a few references to the volumes required under the new RFS, nobody focused on the environmental safeguards and GHG standards. But this is where scientists need to get most involved! How should we implement these requirements? What will they accomplish? Is that enough? How do we go further? These are big questions, I know, but this is where ESA and its members need to engage.

As I listened to presentations that involved economics, those that were starting to incorporate the thinking in the two Science articles, and those worried about biofuels exacerbating the current impacts of agriculture and forestry, an important question formed in my head. I might even go so far as to call it a paradox (I said I was feeling philosophical, and in any case, it's my birthday and I can't talk so cut me some slack). Here it is: The best tools we have for understanding the impact of technologies, policies, and other changes to large complicated systems like markets assess the change in the system when there is a small change involving whatever is the subject of our analysis. So for example, Searchinger et al. tried to estimate the marginal change in GHG emissions in the global land-use system that would be caused by the production of one gallon of ethanol from corn land. But one thing that working on stopping global warming has taught us is that we cannot achieve a sustainable future by changing just one part of the system. In part, this is because no one method of reducing GHG emissions can be large enough. But, some might argue, looking at marginal analysis can at least tell us whether something is part of the solution or part of the problem--is it moving us marginally in the right direction? However, what I've started to ask myself is if the system needs a major overhaul--a step function change--could options that look negative on a marginal basis in the context of the current system actually be positive in the context of a rationalized system. And if the answer is, as I suspect, yes, then how do we manage the small part of the system while working on the major overhaul.

To be a bit more concrete, given the dynamics that Tim Searchinger has identified, biofuel produced from prime agricultural land that displace food and feed production are at least not as good as we had hoped and probably bad for the climate. But this is only true in the context of the current global system around deforestation, or more accurately, the lack of a system. To stop global warming, we eventually need to stop deforestation especially in the tropics, and if we can do that, then from climate perspective biofuels from prime ag land goes back to whatever level of benefits we think they have now. (Impact on food prices is another matter that still would need to be addressed.) So do we stop producing biofuels on prime agricultural land until we solve deforestation? Do we have time to sequence all of our solutions perfectly?

Fortunately, we don't have to wait for biofuels. There are significant amounts of biomass out there that doesn't compete with food, feed, or fiber for land and much more that can be developed. A number of presenters at the ESA conference mentioned winter cover crops, and one questioner from the floor (Prof. Scott Swinton from Michigan State) actually raised the question of what it would take to get farmers to plant cover crops. According to Prof. Swinton there isn't great data on cover crops, but on ERS's website, I did see a quick reference to 4% of harvest cropland being double cropped in 2002. That's about 13 million acres. From another conversation, with a grad student, I understand that current yields from cover crops are pretty low, maybe about 1 ton per year. If we could increase cover crops to, say, 1/3 of all crop land (~113 million acres) and increase yields to, say, 3 tons, then we have about 300 million tons of material that did not interfere with food, feed, or fiber. That's more than enough to meet the current RFS requirements for advanced biofuels.

Now today, cover crops can provide significant environmental benefits helping to keep the soil in place and absorbing excess nutrients that would otherwise runoff (e.g. see this presentation [big PDF] on biofuels and water quality in the Chesapeake Bay watershed and this study by Kim and Dale, which shows how cover crops allow for more residue removal). Can we figure out how to dramatically increase the number of acres under cover crops and increase the yield from the winter crops, and preserve these benefits?

Add in ag residues that are really residues and not needed for the soil or nutrients and forest residues from privately owned wood plantations that are really residues, and recapture and revitalize some ag lands that have been degraded and left fallow, and you start having a significant supply of truly low-carbon biomass that doesn't have any land-use carbon debt (and may actually provide a host of environmental benefits if done right). There is certainly enough to launch the cellulosic biofuels industry, while we figure out how to solve deforestation.

[Side bar: I've heard from two sources now that corn cob removal may actually be purely good for the land. Something about these big, slow to degrade, chunks of biomass aren't great for the soil and also are a significant source of neutral runoff. I understand that some studies are underway, but if anyone has more information on this, I'm all ears (pun intended). At about 0.65 tons per acre, collecting cobs from all our corn land would produce over 50 million tons of biomass. At 100 gallons per ton, that 5 billion gallons.]

So how do we get farmers and biofuels refiners to build an industry around this type of material? Well, we develop rigorous regulations for the RFS that factor in land-use emission, using the best science, as the law requires, and we enforce the environmental safeguards as the law requires. We probably also need some new farm bill programs and to shift our current biofuels tax credits to help farmers start to grow and collect this type biomass and encourage biofuels producers to go our and source it.

A lot of folks think that getting good biofuels is going to be a lot harder in light of the indirect land-use emissions. We can no longer assume that all we have to do is convince farmers to stop growing commodity crops and start growing energy crops. But the reality is that was never going to be an easy sell and these alternative ways of integrating biomass production into food, feed, and fiber production are not likely to be any tougher.

Still struggling with land-use change and biofuels

2008-02-20T04:51:23Z

The debate about biofuels has always been painted with a wide brush and bounced between extremes. One week there's a report that says crop A or conversion technology B is promising and everyone is gaga; the next week, some new study how to do biofuels wrong grabs the spotlight and there's nothing but dire predictions and "I told you so."

The Searchinger et al. paper in Science two weeks ago seems to be a different beast. The scale of the impacts predicted are huge, they attach to any biomass that diverts arable land away from food, feed, or fiber production, and they were, even before the study hit the streets, squarely in the sights of federal and California regulators. So while many of the discussions I've had about emissions from land-use change and biofuels have had a feeling of college econ 101 study sessions, the debate is not academic.

My friend, Ruth Scotti, who works in the biofuels industry, put the challenge of processing the Searchinger analysis well when she asked: what's the truth, what can be measured, and what's important? Paraphrasing and mixing in some of my own thoughts, the truth is underlying supply and demand dynamic. As I said last time, I see this as undeniable. What can be measured is a much trickier question, but the critical one at this juncture. I was alarmed to hear today that the predictive validity of very few, if any, economic models are tested with back-casting. This is a process of putting in old data and seeing if the model accurate predicts some historic period. Back-casting is used regularly to evaluate climatic models. The human element makes economic system less predictable, but not random. There are at least three models being used to look at land-use impacts of biofuels--Iowa State's FAPRI, Texas A&M's FASOM, and Perdue's GTAP. In short order, it will be important to run these models with similar inputs and to test them with some type of back-casting.

The question of what is important has already been answered in CA with the low-carbon fuel standard and at the federal level through the renewable fuel standard with its lifecycle GHG emissions standards and land-use safeguards. As my colleague Roland and I have written about, a federal low-carbon standard is a critical next step to further focus on what's really important--reducing the global warming pollution associated with our transportation sector.

Two concerns that spent some time thinking through are the fairness of regulating indirect land-use emissions and novelty of including these type of emissions in regulations. Ultimately, I disagree that including the dynamic of indirect land-use in regulations is unfair or unprecedented. Especially while we still do not have international protocols that pay to protect or simply prohibit clearing of carbon rich lands, emissions from cleared land driven by marginally higher demand is simply a function of the laws of supply and demand. Just as giving a gun to a person you know to be crazy makes you criminally liable for that person's actions with that gun, we as a country must take responsibility for production (agricultural or manufacturing for that matter) we effectively export to countries that are not protecting their carbon rich lands. Furthermore, we assume supply and demand to hold true when we allocate lifecycle emissions from ethanol production to co-products.

Nor is this the only example of calculating second order impacts. Most modeling of the impacts of CAFE increases (including that done within NRDC) does include second order economic impacts. We model the effective lower price per mile of a more efficient vehicle causing more vehicles-miles-traveled. For every 10% lower cost of driving, our model assumes a 1% increase in the miles driven. This “take-back” or “rebound” effect is also common to models of savings from more efficient appliances. Similarly, there are many instances of regulations factoring second order impacts. For instance, NOx and VOC are regulated both for their direct impacts and because they cook into ozone.

Finally, options such as cover crops, ag residues, and new crops that produce more feed, food, fiber and biomass for fuel that there much that farmers can do to minimize these impacts. We should be working to make sure that these practices have the highest economic return for farmers not trying to deny the impacts of more business as usual.

Biofuels: not quite dead yet, thankfully

2008-02-09T00:51:31Z

So the questions I've been getting today are do yesterday's Science articles mean that all biofuels are bad and that the recently passed RFS is going to harm the climate? The short answer is no and no. It remains relatively easy to construct theoretical scenarios where biofuels contribute significantly to our transportation energy needs in a low-carbon way, avoiding the direct and indirect land-use traps addressed in the articles. The challenge remains how do we drive the biofuels industry to produce these types of biofuels.

Unfortunately, most stories today on the articles are righting off all biofuels and giving short shrift to the policy questions. (See this Wired story and this NY Times article.)On the other extreme, Bob Dineen from the Renewable Fuels Association calls these studies "simplistic," and in a comment on my post from yesterday, Tim Raphael from Pacific Ethanol tried to discredit the whole idea of indirect impacts.

The dynamics the authors have identified are undeniable--if you clear land to grow crop for biofuels you have to account for the emissions from that clearing and if you induce clearing by driving up crop and land prices, you also have to take responsibility for those emissions. For laying out these dynamics and giving us a sense of the scale, we all owe them a debt of gratitude, particularly Searchinger and his team because the emissions from indirect land are hard for many to understand. The analysis of the indirect land-use impacts uses one of the most respected agricultural economic models, but it is only that--one model. Others have been doing similar analysis using at least partly a different model and getting different results. And many folks will make the case for different assumptions and inputs into the models.

Fortunately, we knew about these dynamic before yesterday, and we’ve won a preemptive victory in getting the dynamics written into the legislation in the form of the land-use safeguards and minimum lifecycle GHG standards (which as I noted a few weeks ago include, by law, the indirect land-use emissions). Now we have to defend these provisions and make sure a scientific debate (not one issue of Science) guides the implementation.

So I would caution folks from assuming that either article means that no crop-based biofuels will be able to comply with the RFS or that their analyses are definitive. Of course, it is definitely possible (and taking Searchinger's numbers at face value very likely) that the amount of truly low-carbon biofuels we can drive through real politics and real markets is much smaller than we would hope. This makes the urgency around getting a federal low-carbon fuel standard all the greater. (See Roland's post on this too.) This approach broadens the competition among low-carbon energy supplies for transportation and focuses purely on the benefits we need rather than number of gallons produced.

The challenges of getting biofuels right also means that we need to step up our efforts on renewable electricity, transmission, and electrification of transportation. Similarly, demand reductions are almost always the cheapest, cleanest, and fastest way to reduce GHG emissions. We need to be looking for ways to dramatically increase VMT reductions and further increase vehicle efficiency (beyond our recent victory increasing CAFE standards).

But recall that we’re struggling with how to get biofuels on the right path not out of some perverse desire to work on difficult tasks, but because the other parts of the transportation solution set also face major challenges in scaling up and doing it quickly. The pie-charts above are based on very aggressive scenarios for plug-in hybrids and smart growth/VMT reductions and different levels of efficiency. There are no easy solutions to a low-carbon transportation sector that do not require a significant contribution from biofuels. The challenges facing vehicle efficiency, electrification, VMT reductions, smart growth are different from those facing biofuels (they lessen the benefits we can get instead of risking costs), but for me, they do mean that the just-say-no approach to biofuels is irresponsible.

Two Science articles make the risk of bad biofuels clear

2008-02-07T20:13:40Z

Two articles appearing today in Science Magazine make the risk of bad biofuels clearer than ever. The first article, "Land Clearing and the Biofuel Carbon Debt," addresses the direct greenhouse gas emissions from growing biofuel feedstocks on land recently converted from natural ecosystems to managed agriculture. This article is by a team from the Nature Conservancy and the University of Minnesota including David Tilman. The second article, "Use of U.S. Croplands for Biofuels Increases Greenhouse Gases Through Emissions from Land Use Change," addresses the emissions from land use change induced by the economic pressures when crops and land are diverted from food, feed, and fiber to fuels. This article is by a team lead by Tim Searchinger now from Princeton, the Woods Hole Research Center, and Iowa State's CARD.

While these two article will no doubt stir a lot of debate about the specific amounts of carbon released from different land types, the amounts of different lands being cleared, and the exact economics driven by growth in biofuels production, three conclusions are crystal clear now: 1) Under business of usual, these two dynamics make it very likely that most biofuels would be responsible for greenhouse gas emissions significantly higher than gasoline or diesel; 2) The fundamental dynamics addressed by these two articles (direct land use emissions and economically induced land use emissions) are undeniable; and 3) Because of these dynamics, the importance of minimum GHG emissions standards and land-use safeguards (see this post) in the recently adopted renewable fuel standard is clearer than ever.

Unfortunately, before EPA has even launched a formal rulemaking, some in Congress appear to be itching to gut the standards and safeguards. Today, the Senate Committee on Energy and Natural Resources held a hearing on the renewable fuel standard and a number of Senators raised questions about the standards and safeguards and the need for "technical fixes." (See this article regarding recent comments by Sen. Thune about his desire to use the Farm Bill to start the gutting around some of the forest protections.)

Let's be clear: the environmental protection provisions in the RFS make it possible for the 36 billion gallon goal to be good for our climate and not destructive of our forests, prairies, and wild places. Obviously, whether it works out this way depending on how well we implement these safeguards. Fortunately, while these articles are just running today, the threats they enumerate shaped the RFS protections. We need to go further; we need to adopt a federal low-carbon fuel standard, but definitely at the head of the class now.

But if we gut these protections, these articles make it clear that the RFS will make global warming worse and lead to greater clearing of rainforests, savannas, and millions of acres of natural ecosystems. Without these protections, it's not that the RFS will be less good--it will be very bad!

EU moves to catch up with US on smart biofuels policies

2008-01-25T01:18:27Z

Today is a good day for stories about the world waking up to the complexities of getting biofuels right. This post by FarmPolicy is a great summary of EU biofuels with lots of good links. My sense is that is a weird twist on stereotypes, the US Congress is ahead of the EU on this, with stricter GHG standards and land-use protections (assuming we can get these provision well implemented).

Unfortunately, while the EU is moving towards setting minimum greenhouse gas emissions reduction standards for biofuels, they have so far chosen to skirt the issue of emissions from indirect land-use changes. According to a leading expert on biofuels policies around the world (who will go nameless because I don't have her permission to quote her yet):

For political reasons they couldn't get "indirect land use" included, so what they did was make the default values for direct land use extremely conservative in order to try to also capture some indirect land use impact there. That was the best they could do this time around.

The next month should be an exciting time on the indirect land-use emissions issue. With some luck we'll see at least one peer-reviewed article presenting the first estimates of these emissions drawing on an actual economic model of domestic and international land-use in agriculture. This will take the debate well beyond Dr. Farrell's "crude upper limit." (Available here.) Also I'm hopeful that we'll hear more about how EPA has been thinking of tackling this problem. Because of the work EPA staff did thinking through how to implement the 20-in-10 executive order, they are certainly among the foremost experts on how to integrate the indirect land-use emissions into regulations.

Then there is this article in the NY Times about EU countries redirecting indiscriminate, volume-based biofuels subsidies towards only biofuels produced with low lifecycle GHG emissions and the best production practices. These subsidies are one area where EU countries are pulling ahead, but we're working to fix the US biofuel tax credits ASAP. They all come up for reauthorization in 2010, so next year will be crunch time.

[On a personal note, I'm going on vacation next week, so it will be a bit longer than usual between posts.]

Low-carbon fuels, land-use, and Massachusetts

2008-01-17T22:43:04Z

Today I testified before the Massachusetts Advanced Biofuels Task Force on what the state should do to promote biofuels. Here's my testimony, which boils down to encouraging them to adopt technology-neutral, performance-based policy and ideally adopt a low-carbon fuel standard. I was proceeded at the hearing, by Dr. Dan Sperling and proceeded by Jonathan Lewis from the Clean Air Task Force. All three of us touched on the importance of the lifecycle greenhouse gas emissions accounting and certification protocol being developed by CARB (here's CARB's LCFS page) and EPA.

My written testimony was 19 pages long and I only had 8 minutes to speak, so of course I had to summarize, but here's what I wrote (for more thoughts on the letter mentioned below see this recent post):

A recent letter in Science does a particularly good job of showing how complicated but important these indirect land-use impacts can be. The letter explains how increased demand for corn to make ethanol is reducing domestic production of soy beans and thus driving up the production of soy beans in Brazil. Policies such as the biodiesel mandate being contemplated in Massachusetts would great similar pressures on Brazilian soy farming. The letter details how increased Brazilian soy farming leads directly and indirectly to clearing of Brazilian rainforests:
Some Amazonian forests are directly cleared for soy farms. Farmers also purchase large expanses of cattle pasture for soy production, effectively pushing the ranchers farther into the Amazonian frontier or onto lands unsuitable for soy production. In addition, higher soy costs tend to raise global beef prices because soy-based livestock feeds become more expensive, creating an indirect incentive for forest conversion to pasture. Finally, the powerful Brazilian soy lobby is a key driving force behind initiatives to expand Amazonian highways and transportation networks in order to transport soybeans to market, and this is greatly increasing access to forests for ranchers, loggers, and land speculators. [Footnotes not included.]
Not all biomass material leads to increased demand for new agricultural lands and not all lands brought into production are rainforests. Nevertheless, it is important to understand the scale of impact that greenhouse gas emissions from these indirect land-use changes can have. Looking at a number of estimates, new very efficient corn ethanol refineries should be able to produce about 420 gallons of ethanol from an average acre of corn. Putting aside emissions from land-use change, this ethanol would reduce greenhouse gas emissions by about 37 percent per gallon or about 2,500 pound worth of CO2 per acre each year. Now, according to another article in Science, one acre of tropical rainforest if cleared and used to grow crops will release about 655,000 pounds worth of CO2 over 30 years or an average of nearly 22,000 pounds per year. In other words, if the conversion of an acre of corn from food and feed to fuel resulted indirectly in the conversion of just one-tenth of an acre of rainforest all the greenhouse gas emissions benefits of the ethanol would be whipped out for the first 30 years.
Of course, there are many more types of land being converted to agriculture than just rainforests. And the marginal impact of land-use changes here in the United States on land-use in the rest of the world is extremely hard to predict with economic equilibriums and agricultural and trade policies all interacting in complex ways. But to ignore these indirect emissions is to assume they are zero, which could easily lead to the government subsidization of fuels that are worse for global warming than gasoline or diesel.

Here's what I had to say about the EPA and CARB processes:

In December of last year, President Bush signed into law the Energy Independence and Security Act of 2007 (EISA07), which included a major increase in the renewable fuel standard and groundbreaking GHG performance standards and safeguards for renewable fuels. Specifically, the expanded RFS requires the oil companies to use 36 billion gallons of ethanol (or the equivalent of other renewable fuels) by 2022. Over their full lifecycle, all of these renewable fuels must provide at least a 20 percent reduction in greenhouse gas emissions compared to petroleum fuels. The new RFS also requires that at least 22 billion gallons of the 36 billion total be “advanced biofuels,” which are basically defined as not being ethanol from corn. These advanced biofuels must provide at least a 50 percent reduction. Of the advanced biofuels, at least 16 billion must be from cellulosic feedstocks and at least 1 billion must serve as an alternative to petroleum diesel. The advanced biofuels from cellulosic feedstocks must provide at least a 60 percent reduction in GHG emissions.
The RFS also establishes clear parameters for sustainable sourcing of biofuels feedstocks that guard against the loss of native forests and prairie, and protect threatened, imperiled, and endangered species, and public lands. While additional safeguards such as conservation standards to preserve soil and water quality are needed, the RFS contains critical safeguards necessary to protect our natural resources.
Under the EISA07, EPA is directed to promulgate regulations to implement these GHG performance standards and the environmental safeguards by the end of 2008. Perhaps the most complicated part of this is developing the accounting protocol to measure and certify the lifecycle greenhouse gas emissions of different renewable fuels. Fortunately, EPA has a head start in this effort. Early in 2007, President Bush directed EPA, in coordination with other federal agencies, to promulgate regulations to reduce US gasoline use by 20 percent within 10 years and to do so in a way that complied with the federal court ruling that CO2 is a pollutant. Before the passage of the EISA07, EPA was track to issue a notice of proposed rulemaking to implement the so called 20-in10 executive order around the end of 2007. As part of these draft rules, EPA had done significant work developing a lifecycle accounting methodology.
The California Air Resource Board is also developing an accounting protocol as part of the low-carbon fuel standard and is on a similar schedule as EPA. The LCFS was the first measure announced after the signing of the landmark AB32 Global Warming Solutions Act, and is the world’s first global warming pollution standard for fuels. Governor Schwarzenegger’s executive order implementing the LCFS directs CARB to develop a regulation for oil companies and other providers of vehicle fuels sold in California to reduce emissions of carbon dioxide and other global warming pollutants by 10 percent by 2020. CARB is scheduled to adopt the LCFS at the end of 2008.
A LCFS is a better approach to encouraging innovation among fuels and reducing global warming pollution than an RFS. A LCFS is technology-neutral allowing any type of low-carbon fuel to compete in reducing the average GHG intensity of fuels including electricity. Furthermore, while the new RFS provides a minimum level of lifecycle GHG performance, the LCFS encourages the best performance. Finally, a LCFS discourages high-carbon fuels such as liquid coal, oil shale, and tar sands. An RFS has no impact on these more polluting fuels.

In a related matter, yesterday Dr. Alex Farrell from UC Berkeley, who is under contract to advise CARB on developing the LCFS regulations, posted a spreadsheet with some "crude upper limit" estimates of the land-use related GHG emissions. I haven't had a chance to digest these, yet, but it's clear that these emissions have the potential to be huge. (Here's Alex's memo explaining the basics of his spreadsheet.)

It's becoming increasing clear that getting a clearer read on these emissions and figuring out how to incorporate them into the California and federal regulations is one of the ultimate challenges for biofuels policies.